By MichaelSilver
Nationwide Injunction Lifted
Following a February 18, 2025 court decision, the previous nationwide injunction on Beneficial Ownership Information (BOI) reporting has been lifted. BOI reporting requirements under the Corporate Transparency Act (CTA) are now back in effect.
Reporting Deadline
Extended Deadline – FinCEN has extended the reporting deadline for most companies to March 21, 2025. Companies with later reporting deadlines (e.g., due to disaster relief) should follow their original later deadline.
Key Exemptions & Considerations
National Small Business Association Exemption – Members of the National Small Business Association (as of March 1, 2024) remain exempt from reporting requirements, as determined in the National Small Business United v. Yellen case.
Future Modifications
FinCEN plans to assess further deadline modifications during this 30-day period. Future revisions to the BOI reporting rule are expected to reduce the burden for lower-risk entities, including many U.S. small businesses.
How to Report
Companies can submit BOI reports directly through FinCEN’s E-Filing system: https://boiefiling.fincen.gov/ (free of charge).
Penalties for Non-Compliance
Willful failure to comply with the BOI reporting requirement can result in:
• Criminal and civil penalties of $606 per day and up to $10,000 total
• Potential imprisonment of up to two years
• Similar penalties apply for unauthorized disclosure of information
Additional Resources & Legal Disclaimer
Additional Resources – Available at https://www.fincen.gov/boi.
Historical Context – General information on the BOI reporting requirements was previously discussed in a Silver Advantage Alert, which can be reviewed here: https://michaelsilver.com/corporate-transparency-act-beneficial-ownership-information-reporting-requirement/.
Legal Advisory – Please note that CTA/BOI filings are legal matters. We are not able to advise clients on these requirements directly.
We recommend consulting with your attorney to determine your specific obligations. While we cannot assist with the filings directly, our team is available to collaborate with your legal counsel as needed.
Contact
If you have questions about this notice, please contact your trusted advisors at 847-982-0333.